With the release of the Health Resources and Services Administration (HRSA) Health Center Compliance Manual (HRSA Compliance Manual), health centers were provided the flexibility to determine whether or not clinical staff must go before the health center Board of Directors for final approval.   

Included in Chapter 5 – Clinical Staffing of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 5 – Clinical Staffing) is a section titled “Related Considerations.”  Within this section there is a bullet point that states, “The health center determines who has approval authority for credentialing and privileging of its clinical staff.”  Likewise, the Credentialing and Privileging Policy and Procedure no longer requires board approval.  As outlined in the “Demonstrating Compliance” section of Chapter 19 – Board Authority  of the HRSA Health Center Compliance Manual (Compliance Manual Chapter 19 – Board Authority), the only clinical policies requiring board approval are those associated with Quality Improvement/Assurance. 

Although board approval of clinical staff is no longer required, many health centers continue to present their clinical staff to the health center Board of Directors for approval to implement industry standard best practices.  It is important to remember the guidance outlined in the HRSA Health Center Compliance Manual provides the minimum standards to meet compliance.  In contrast, the highest standards for compliance are outlined in the Federal Tort Claims Act Health Center Policy Manual (FTCA Manual).